political engagement

policy committee

Target’s Policy Committee is the primary body to guide the decision-making process regarding financial support of political activities. The Policy Committee consists of the Executive Leadership Team. The Policy Committee, in conjunction with the Chief Executive Officer, is responsible for balancing our business interests with any other considerations that may be important to our team members, guests or other stakeholders. The Policy Committee reports to the Nominating and Governance Committee of the Board of Directors at least twice per year.

Target may provide financial support to political candidates, political parties or ballot initiatives through two separate channels:

TargetCitizens PAC, which is funded through the voluntary contributions of our eligible team members, and

The use of general corporate funds where permitted by law.

Regardless of which channel for political contributions is used, our financial support is provided in a bipartisan manner based strictly on issues that directly affect our business priorities.

PAC contributions

TargetCitizens PAC, which is funded through the voluntary contributions of eligible team members, makes contributions in a bipartisan manner to federal candidates and organizations. Target’s Policy Committee approves the factors to be considered when making contribution decisions. These factors are:

General alignment with our business objectives

Extent of our presence in a candidate’s state or congressional district

Relevant legislative committee assignments

Leadership positions

Political balance

The interests of our guests, team members, shareholders and other stakeholders

TargetCitizens PAC Contributions

political contributions

Bipartisan

Republican

Democratic

2% / $5,000

49% / $105,000

49% / $105,000

corporate contributions

The use of general corporate funds for political contributions is permitted if the Policy Committee determines that it would be an appropriate means of advancing issues that are important to our business. The Policy Committee reviews and approves any use of general corporate funds for electioneering activities, including any contributions to political candidates, parties, committees or other political organizations, or for or against ballot measures.

The Policy Committee: (i) determines whether the contribution supports our business interests; (ii) gives consideration to the interests of our guests, team members, shareholders and other stakeholders; and (iii) determines whether under the circumstances, the contribution is an appropriate means of advancing our public policy position. This Policy Committee approval process applies whether the contribution is made directly to a candidate or party, or indirectly through an organization operating under Section 527 or 501(c)(4) of the U.S. Internal Revenue Code.

One way Target and other retail companies engage at the state level is to support state retail association political action committees (PACs) where allowed by law. By pooling resources with other retailers, we are able to support candidates who understand and support issues important to the retail industry, such as tax and labor policy, environmental and health care issues. Target also is a member of national organizations such as the Democratic and Republican governors associations and state legislative campaign committees, which allows our team members to attend conferences and other events to learn about those elected officials’ policy priorities and initiatives and to share a retail perspective. Target expressly requires that our funds are used only to support educational and association management activities and not for campaign contributions. Because those organizations also engage in political efforts, we disclose our memberships as political contributions.

Target publicly discloses its political contributions using corporate treasury funds, which include contributions to recipients such as political candidates, parties and committees; 527 or 501(c)(4) organizations using the funds for political purposes; super PACs; governors associations; and independent political expenditures supporting or opposing campaigns or ballot measures. A list of such individual contributions of $5,000 or more, including recipient name and amount, is updated twice per year and available below.

All Target team members are required to comply with the foregoing corporate policies on public policy engagement and political contributions. Legal counsel reviews and approves all TargetCitizens PAC reports and materials.

Government Affairs staff and key internal business partners complete annual training and certify compliance with corporate policies on public policy engagement and political contributions. Target corporate political contributions and lobbying practices are subject to periodic internal audit.